PRIVACY POLICY - E-LEARNING PLATFORM

Pursuant to arts.13 and 14 of the EU Regulation n. 2016/679 (hereinafter “GDPR”), This policy provides the User some information about categories, purposes, and the way of processing Personal Data (hereinafter “Data”) that are collected via the e-learning platform of TEXA S.p.A (hereinafter “Platform”).

1.DATA CONTROLLER

The data collected through the Platform will be processed by TEXA S.p.A. (hereinafter “TEXA“) as Data Controller for the courses organized and provided directly by TEXA. For the exercise of your rights and for any other matter relating to the processing of data, the interested party may contact TEXA by sending a written request to the e-mail address: privacy@texa.com. TEXA has appointed a Data Protection Officer, who can be contacted at: dpo@texa.com.

For courses provided by third parties to whom TEXA provides the use of the Platform, TEXA processes the data as Data Processor pursuant to art. 28 of the GDPR on behalf of the Data Controller. In such cases, the Data Subject must also refer to the information provided by each Data Controller.

2.CATEGORY OF PROCESSED DATA

Registration to the Platform is necessary to access the training courses in e-learning/online mode and to your private area.

For registration on the platform, we require some common personal identification data (name, surname, e-mail address, Tax Code) necessary to allow the identification of the Data Subject and the creation of the relevant login credentials.

Such data may be collected by TEXA directly from the Data Subject during registration on the Platform or provided by the Company/Entity to which the Data Subject belongs and/or through its Authorized TEXA Dealers (hereinafter “Dealers“) acting as Data Processors in the context of the activities carried out on behalf of TEXA.

The following data may also be collected and processed when using the platform:

• profile image when uploaded by the Data Subject
• logging access to the platform (log)
• completion of training activities
• the image and/or audio if the Data Subject during the training sessions interacts using the webcam or microphone.

 3.COOKIE

The e-learning platform does not involve the use of profiling cookies or third parties, but only technical session cookies, necessary for its operation and for the correct management of the training path, by authenticating the user’s access data to the platform.

4.PURPOSES AND LEGAL BASIS FOR PROCESSING

The personal data of the Data Subject will be processed only for the purposes of providing training courses and for the performance of organizational, technical, assistance and security activities related to the provision of the services.

For these purposes, the processing of personal data is necessary for the execution of the Contract of which the Data Subject or the Company/Entity to which the Data Subject belongs is part for the training services required.

5.METHOD OF PROCESSING

The processing of Data may be carried out by TEXA with the help of both analog and electronic or automated means, with methods and procedures strictly necessary for the pursuit of the purposes described above. In particular all technical, IT, organisational, logistical and procedural security measures will be taken, so that adequate data protection is guaranteed, allowing access only to authorised persons for the processing of personal data.

6.CATEGORIES OF SUBJECTS TO WHOM DATA MAY BE COMMUNICATED

The Data will be processed by the employees and/or collaborators of the Data Controller who have received appropriate operating instructions and who have been expressly authorised to process them. In addition, the data may be communicated to:

• Professionals (e.g. teachers) appointed by TEXA to provide training courses;
• Entities whose communication for the execution of certain types of courses is required by law (e.g. Chamber of Commerce DNV, CEI);
• companies/ third parties/ i who will perform on behalf of TEXA technical, organizational and operational tasks and will be designated as Data Processors pursuant to art. 28 of the GDPR (e.g. IT service providers, E-learning platform provider).

7.TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANISATIONS

The Data are not transferred to third countries (non-EU) or international organizations. If necessary for the provision of the Service requested, they may be transferred to entities located in countries outside the EU, where the European Commission has recognised that such countries have an adequate level of data protection or on the basis of appropriate safeguards (such as standard contractual clauses or corporate rules binding on groups), or, in the absence of such conditions, if the transfer is authorized by the Data Subject or necessary for the performance of the Contract.

8.DATA RETENTION PERIOD

The personal data collected will be stored by TEXA for the time necessary for the pursuit of the purposes described above and unless the storage is required by laws, regulations or provisions issued by the Authority, once the purposes of the processing cease to be used, they will be permanently deleted.

In order to allow the Data Subject to enjoy the educational content on the Platform and its reserved area, the Platform access account and data will be kept until the cancellation request received by the Data Subject from TEXA.

9.RIGHTS OF DATA SUBJECTS

With regard to the provided Data, the GDPR (articles 12 and 15-22) grants that every Data Subject can exercise the right to access the data concerning him or her and the information about processing; to rectify or integrate the data if inaccurate or incomplete. Moreover, where the conditions set forth by the regulation are met, the Data Subject can exercise the right to erasure of the Data; to restriction of processing; to Data portability intended as the right to obtain the data by the Data Controller in a structured, commonly used and machine-readable format to transmit those data to another controller without hindrance; to object to processing; not to be subject to a decision based solely on automated processing. If the Personal Data processing is based on consent, the Data Subjects have the right to withdraw their consent, without prejudice to the lawfulness of processing performed before the withdrawal.
Furthermore, if you believe your rights have been harmed, you can lodge a complaint to the Guarantor for the Protection of Personal Data.